ML20154B868
| ML20154B868 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/08/1988 |
| From: | Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-7055 OL-1, NUDOCS 8809140169 | |
| Download: ML20154B868 (37) | |
Text
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(
DOCKETED U5NPC TB SEP 12 P,1 :28 September 8fC1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al.
)
50-444-OL-1
)
On-site Eme:gency (Seabrook Station, Units 1 and 2)
)
Planning an? Safety
)
Issues
)
APPLICANTS' MOTION FOR SANCTIONS AGAINST THE MASSACHUSETTS ATTORNEY GENERAL FOR FAILURE TO COMPLY WITH THE BOARD'S DISCOVERY ORDER Applicants hereby move, pursuant to 10 C.F.R. 5 2.707, that the Board dismiss bases A.3, A.5, and A.2 of the Amended i
Contention on Notification System of the Attorney General for the Commonwealth of Massachusetts ("Mass AG"), as a necessary and proper sanction for the Mass AG's failure to comply with the Board's Memorandum and Order (Rulina On Aculicants'
(
Revised Motion to comoel), ASLBP No. 88-558-01-OLR (August 19, 1988) (hereinafter the "Order") requiring Mass AG to answer certain interrogatories and produce certain documents.
Applicants also move, firsuant to 10 C. F.R.
5 2.711(a),
that the Board shorten the time 11r response to Applicants' 0809140169 00 j43 0
motion for sanctions.
In view of the fact that Applicants must file, in hand, their summary disposition motion on the Amended Contention on Nocification System no later than September 15, 1988, Applicants respectfully suggest that the Board hold oral argument of the sanctions motion at 10 a.m.,
Monday, September 12, or such other time as is convenient for the Board.
DISCUSSION On August 19, 1988, the Board issued an order requiring Mass AG to produce certain documents and answer certain interrogatories within two weeks.
Order, slip op. at 3, 5,
7, and 8.
On September 6, 1988, the Mass AG filed "Massachusetts Attorney General's Additional Responses to Interrogatories and Production of Documents" (the "Responses") and produced photo copies of certain documents and photographs.
As discussed below, the Responses were wholly unresponsive to five of Applicants' interrogatories and document requests.
As a result, Applicants are severely prejudiced in litigating tha three contention bases at which the interrogatories were aimed -- indeed, Applicants are left, just a few days short of the deadline for summary disposition, with no clear information of what they are supposed to litigate.
Accordingly, it is appropriate that these three bases be dismissed.
l l -
1 1.
Interrocatory 12 -- Basis A.3 The roard ordered Mass AG to respond to the following interrogatory:
12.
Please state in detail all the facts underlying the Mass AG's assertion that "the fourteen VANS locations are physically inaccessible to the VANS equipment",
define precisely what is meant by "physically inaccessible", and explain exactly how those facts support the assertion.
The quoted language in the interrogatory tracks, word for word, the entire text of Mass AG's Basis A.3.
In a previous answer, Mass AG defined "physically inaccessible" as "the inability of fully loaded VANS trucks and equipment to drive into and set up at the acoustic locations," but declined to state any facts underlying the assertion.
In response to the Board's Order compelling an answer, Mass AG states, in full:
Reseense 12:
On August 10, 1988, representatives of the Mass AG's office viewed the acoustic locations and took photographs showing the accessibility, or lack thereof, of each such location.
Based on that information, the Mass AG believes that the following locations are inaccessible:
VL-02; VL-03, VL-06; VL-07; VL-12; VL-13.
copies of these photos are attached hereto.
Accompanying the Responses were 22 black-and-white photocopies of what the Mass AG apparently purports to be photographs of those six acoustic locations, which are attached hereto as Exhibit A.
Mass AG states his belief that Applicants' VANS trucks cannot drive into and set up at these six locations.
Rather than state the facts underlying that belief, as asked and then ordered to do, Mass AG has handed Applicants a fistful of blurred photocopies and invited Applicants to guess what facts, if any, those pictures purportedly portray.
Applicants should not be obligated to engage in such guessing games, especially when a motion for summary disposition is about to be filed.
NRC regulations and case law require that intervenors in NRC proceedings must reveal the factual basis for their contentions when asked to do so in discovery.
Pennsylvania Power & Licht Comoany (Susquehana Steam Electric Station, Units 1 and 2), ALAB-613, 12 NRC 317, 339-340(1980) ("A litigant may not make serious allegations against another party and then refuse to reveal whether those allegations have any basis.
Obviously, interrogatories designed to discover what (if any) evidence underlies an intervenor's own contentions are not out of order.").
This Board admitted Basis A.3 to litigation, over the l
objections of Applicants and Staff that it was too vague to I
l put Applicants on notice as to what specific alleged l
deficiency was to be litigated, on the assumption that "the i
Staff and Applicants may seek further information via l
discovery procedures."
Memorandum and Order (Rulinc on -
\\
l Admissibility of Mass. Amended Contention and Bases) (June 2, 1988), slip op. at 5.
Mass AG, however, has thwarted every attempt by Applicants to obtain such further information.
Mass AG's Responses leave Applicants without a clue as to what facts about these six locations allegedly make chem physically inaccessible to Applicants' vehicles.
With no idea what they are supposed to be defending against, Applicants obviously are prejudiced in filing their summary disposition motion due on September 15.
Under these circumstances, in light of the contumacy of Mass AG, the clear prejudice to Applicants, and the detriment to the evidentiary record caused by Mass AG's refusal to disclose his facts, the appropriate sanction is dismissal of the contention which Mass AG's conduct has rendered unlitigable.
Kerr-McGee Chemical Corcoration (West Chicago Rare Earths Facility), LBP-86-4, 23 NRC 75 (1986).
2.
Interrocatories 18 and 20fe) -- Basis A.5 The Board ordered Mass AG to respond to the following interrogatories:
18.
Please state in detail all the facts, analyses and estimates underlying the Mass AG's assertion that "the time needed for driver alert, dispatch, route transit, setup and activation in accordance with NRC regulations will exceed 15 minutes for many of the VANS vehicles in optimum weather conditions", and explain exactly how those facts support the assertion. _
20.
Please state in detail how long the Mass AG contends it will require to perform each of the following functions, for (1) optimum weather conditions and (2) poor weather, heavy traffic, or nighttime conditions, and state in detail all the facts underlying each answer and how these facts (e) VANS vehicle support the answers:
proceeds to acoustic location.
The quoted language in Interrogatory 18, which is followed up upon in Interrogatory 20(w), tracks, word for word, the operative language in Mass AG's Basis A.5.
In response to the Board's order compelling answers to these interrogatories, Mass AG states, in full:
Response 18:
In an earlier response, the Mass AG estimated that performance of various functions inherent in completion of VANS siren notification (1232, dispatch, set-up, activation) would entail a total of nine (9) minutes.
Egg Mass AG Response to First Set of Interrogatories, No. 20. Thus, actual transit time can be no greater than six (6) minutes in order for the VANS system to work within the prescribed fifteen (15) minute time frame.
Based on transit times supplied by the Applicants and based on transit times recorded by reoresentatives of the Mass AG's office durina a oreliminarv investiaation, the following VANS transit routes take longer than 6 minutes:
VL-01,;
VL-03; VL-07; VL-08; VL-09; VL-10; VL-11; VL-12; l
VL;13 (sic); VL-16S.
Whereas the aforementioned routes were timed both by the Applicants and the Mass AG durina licht to moderate traffic and at times when beaches were not fresuented, the transit time involved when beaches are populated and/or during heavier traffic flow and/or during adverse weather would result in significantly longer transit times.
In those cases, the aforementioned routes would be ever further out of the prescribed time frame and other routes which may have oreviousiv taken less than l
l l l
six (6) minutes would similarily (sic) fall out of the recuired rance.
(Emphasis added).
Response 20(e):
Egg Response to Interrogatory 18.
In these Responses, Mass AG reveals, for the first time, that his agents have conducted field tests of the route times to Applicants' acoustic locations.
It is the facts about these tests -- when and how they were conducted, and what specific transit times were observed for each location --
that presumably constitute the factual basis for Mass AG's contention.
It is these facts which Applicants asked for, and which the Board ordered Mass AG to reveal.1 Yet, it is these facts which Mass AG refuses, without explanation or justification, to reveal.
Instead, Mass AG simply states his belief, based upon those undisc2osed facts, that at least 10 of Applicants' acoustic locations are too far from the VANS staging areas.
I That belief, however, is of no probative value, and is of no interest to Applicants.
What Applicants asked for, what the Board ordered Mass AG to reveal, and what Applicants need in order to litigate this basis, are the facts underlying that belief.
l 1
Indeed, to the extent that those tests were documented, Interrogatory 1 required Mass AG to identify and produce the documentation as well..
r As matters now stand, Applicants must file for summary disposition without knowing what facts Mass AG may introduce in response.
Moreover, since Mass AG will presumably then reveal only such selected parts of the test data as arguably help him to counter Applicants' summary disposition motion, the rest of the facts assembled by Mass AG -- which may suonort Applicants' case, as to some or all of the acoustic locations -- would remain forever hidden.
Applicants clearly are prejudiced by this attempt on the part of Mass AG to manipulate the evidentiary record on this contention basis and to conceal key probative evidence.
Since some or all of the evidence hidden by Mass AG may in reality be favorable to Applicants, a sanction order that merely barred Mass AG from introducing it would only exacerbate, rather than cure, the injury done to Applicants' due process rights.
Accordingly, the only sanction adequate to protect Applicants' rights and the integrity of the evidentiary record is to strike the basis to which Mass AG's concealed evidence would go.
Metrooolitan Edison Comoany (Three Mile Island Nuclear Ststion, Unit No. 1), LBP-80-17, 11 NRC 893 (1980).
3.
Interrocatories 6 and 7 -- Basis A 2 t
The Board ordered Mass AG to respond to the following two interrogatories and production requests, while at the same time limiting the evidentiary use that Applicants might make of the Mass AG's responses and production:2 6.
Has any representative of or person employed by the Department of the Attorney General of the commonwealth been in contact with any selectman, civil defense director or other official of Amesbury, Merrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station?
If so, please:
(a)
Identify each selectman, civil defense director or other official who was contacted and the official, representative or employee who contacted them.
(b)
Describe in detail the date, time, manner, place, and substance of the communication.
(c)
Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
7.
Has any other official, representative, or employee of the government of the commonwealth of Massachusetts been in contact with any selectman, civil defense director or other official of Amesbury, Merrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station?
If so, pleases (a)
Identify each seleucman, civil defense director or other official who was contacted and the official, representative or employee who contacted them.
(b)
Describe in detail the date, time, manner, place, and substance of the communication.
(c)
Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
2 order, slip op. at 4-5. -. _ _ _
r As the Board noted, these interrogatories and document requests are directly relevant to Mass AG's Basis A.2, which contands that Applicants' VANS system violates local ordinances.
Mass AG responses to these interrogatories and requests, in their entirety, are:
Response 6:
The Mass AG has already procuced a town ordinance (pertinent to the town of Amesbury) and a communication related thereto.
Other than this, the Mass AG knows of no other such ordinance.
In addition, the Mass AG knows of no communication with a town official which would contain probative evidence bearing on the interpretation of any ordinance.
Response
7:
The Mass AG knows of no communication with a town official which would contain probative evidence bearing on the interpretation of any ordinance.
Mass AG does not deny that his office and/or other state officials have communicated with local officials about Applicants' siren warning system.
Indeed, the single document Mass AG has previously produced reveals that there have been other such communications.
Yet Mass AG refuses to describe those communications and produce their documentation, as asked by Applicants and ordered by the Board.
Instead, Mass AG arrogates to himself the prerogative to decide what is probative evidence on the evidentiary limit the Board placed on Applicants' use of the communications.
Based on that usurpation, Mass AG has arbitrarily withheld l
all evidence concerning such communications.
l l
[
It is not Mass AG's place to decide what evidence is probative.3 Rather, that is for the Board to decide, after Applicants have examined all the communications and have introduced those which Applicants think are relevant.
In order for Applicants to do their job, and for the Board to do its job, Mass AG must do as he was ordered, and turn over the communications.
Mass AG apparently contends that one section of the Amesbury Zoning by-law prohibits operation of Applicants' VANS sirens.
The key question underlying Mass AG's Basis A.2, therefore, is the meaning and validity of that by-law.
As the Board has acknowledged, the communications which Applicants seek may help to reveal how that by-law would be interpretted and applied, and whether its enforcement against Applicants would be valid.
Yet, Mass AG refuses to reveal those communications, taking it upon himself to decide all questions of relevance and probative value.
3 Having previously argued that he should be treated like the NRC staff rather than like any other intervenor, Mass AG now apparently insists that he be accorded powers i
equal or superior to the Board itself.
Egg Massachusetts Attorney General's Resconse to Aeolicants' Revised Motion to comoel at 5 (August 15, 1988) (Mass AG, "like the NRC",
should not be required to answer interrogatories under oath).
For the record, Mass AG is wrong about the facts as well as about his role in these proceedings -- the NRC Staff does an';Ner interrogatories under oath.
Ega, gigt, NRC Staff nasconse to NECNP First Set of Interroaatories and Reauest for the Production of Documents to NRC Staff on NECNP ontention I.B.2.
(July 20, 1988).
a l
r Here again, the evidence concealed by Mass AG may very well be favorable to Applicants.4 Therefore, a sanction order barring the evidence would again only exacerbate the injury to Applicants.
Having refused to produce the evidence which may be relevant, as Applicants asked and the Board ordered, Mass AG can only remedy his wrong by giving up the contention basis to which it would go.
CONCLUSION For the reasons stated above, the Board should dismiss Bases A.3, A.5, and A.2 of Mass AG's Amended Contention on Notification System.
By their attorneys, AM f
Thomas G.
Dignan, Jr.
Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MA 02110 (617)423-6100 l
l 4
Indeed, since Mass AG does not regard it as probative, presumably he does not plan to use f.t at all, and its exclusion can only hurt Applicants.
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CERTIFICATE OF SERVICE I, Jeffrey P. Trout, one of the attorneys for the
'20 EP 12 P1 :28 Applicants herein, hereby certify that on September 8,
- 1988, I made service of the within document by deposit'7g copies g,s where indicated, by depositing in the United States mail,(OD;D q,/>
thereof with Federal Express, prepaid, for delivery to (o
'*Vd WAm first class postage paid, addressed to) the individuals listed below.
Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A.
Diane Curran, Esquire Luebke Andrea C.
Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.
Washington, DC 20009 Dr. Jerry Harbour Stephen E.
Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies)
U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th Fl.
East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105
'4 Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 A"gusta, ME 04333 at.1 McEachern, Esquire Carol S.
Sneider, Esquire rlatthew T.
Brock, Esquire Assistant Attorney General Shatnes & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O.
Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Whilton &
Washington, DC 20510 McQuire (Attnt Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Mr. Peter J. Matthews one Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attnt Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301
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Mr. Richard R.
Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street Agency Se :ond Floor Federal Regional Center Newouryport, MA 01950 130 228th Street, S.W.
Bothell, WA 98021-9796 ffhr.
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